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Sustainability, Intelligence, & Safety chart the path from the Darkweb to the Lightweb

Review of Raffi Cavoukian’s book, “Lightweb Darkweb”

Many people know the author as “Raffi” – a beloved childrens performer behind the classic songs, “Baby Beluga,” and “Bananaphone.” In his new book “Lightweb Darkweb,” Raffi Cavoukian challenges the technology industry to make social media safer for kids, and to make the products safer and more sustainable for all.

I just finished the excellent new book by Raffi (the popular children’s troubadour and author) entitled Lightweb Darkweb: Three Reasons to Reform Social Media Before It Re-Forms Us. I found this book to be inspired and very relevant for anyone working in technology, who’s thinking about the role of technology in our culture, and/or who’s concerned about the impact of technology on our kids. (In fact, I used a yellow marker to highlight the “important parts” and there is a whole lotta yellow in my book now!)

Lightweb Darkweb is a 21st century manifesto and call to action that presents critical information about our Internet culture in a vibrant and clear manner. While the internet and social media have made amazing things possible and accessible (the Lightweb), they also have a profound downside (the Darkweb), particularly for kids, that we must address.

The book is built around three compelling and urgent reasons to reform social media and issues a resounding call for a thorough “mid-course correction” before it is too late.

Reason 1: Safety

Raffi points out that social media (as well as the internet) were not designed for children, which is why we need to protect them from on-line predators (including bullies as well as advertisers). He takes on Mark Zuckerberg directly for wanting to market Facebook to kids. In the words of Jim Steyer of Commom Sense Media:

“Luring younger and younger kids into using FB without any indication it would be good for them is a brazen attempt to increase FB’s profitability. Is this not using the young for your corporate ends? Is this not violating childhood innocence for advertising profits? Is FB turning into a platform for colonizing the child psyche and spirit?”

Instead, he asserts, we need “privacy by design.” Also, Raffi brings to light the latest research on electromagnetic fields and radiofrequency radiation, pointing out the dangers, especially for young children.

Reason 2: Intelligence

“A vast sociological experiment is under way” that is teaching kids to value “artificial reality” over actual reality and real time play (and nature!).

“There are many signs of unhealthy culture in a civilization that currently seems stuck in short-termism, like a juvenile refusing to grow up, needing intervention. One clear sign is a predatory commercial culture and its willful exploitation of the young. Culture as bully. It’s our duty to resist it, to change it, to orient societal priorities towards life-affirming values and to oppose life-destroying practices. Resistance to unhealthy culture is not an option, it’s our duty.” (Emphasis mine.)

I know that things were difficult enough monitoring TV when my wife and I were raising our kids – it is now WAY more difficult with the emergence of social media. And it not just a dilemma for parents – teachers are also under heavy pressure – and Raffi speaks to them directly. He reminds us that the moral imperative is “first do no harm” and reminds us that “there is no app for wisdom – If you’re not grounded in the real world, if you can’t face the complexity of being fully human, how can you possibly thrive in navigating virtuality—or even tell the difference?”

Reason3: Sustainability

The third pillar is the ecology of InfoTech: its manufacture, marketing and life cycle. This is what brings Social Media “to our fingertips….It’s not just about conserving the life-giving qualities of air, water and soil. It’s about a way of living ethically, a code of conduct for our relations with the Earth, with each other and with the future.”

He shines a bright light on the hidden hazards throughout the life cycle of electronics production which fuels our addiction to our gadgets and social media: “all our high-tech gadgets come from a very dirty industry in which rich nations extract the good stuff from the earth—and leave poor countries to clean up the mess.” Our reliance on “cheaply priced goods… have a big ecological footprint” all around the world. He correctly notes that none of us would like to see our own children working 12 hour days around hazardous chemicals to turn out “shiny-tech devices”, and that none of us wants to be on the receiving end of the tons of e-waste generated by planned obsolescence and our throw-away culture. He quotes from “The story of electronics” and “Challenging the chip: Labor rights and environmental justice in the global electronics industry”:

“Challenging the Chip is about challenging the industry to use its incredible ingenuity to dazzle the world all over again with cleaner, greener technologies, products, and components that are free of toxics, easy to recycle, and produced without harm to those manufacturing, assembling, and disassembling them…. the planned obsolescence of electronic devices, which become outdated very quickly, virtually rules out repairing or upgrading existing ones, and that forces consumers to buy new devices and throw out the old. The rapid pace of change is a real double-edged sword because new chemicals are being incorporated before adequate health testing is done, and we are also consuming faster than we can recycle….. An industry that’s been able to put thousands of songs, photos, and videos on a tiny chip has the capacity to pave the way towards a sustainable future.”

In conclusion, Raffi calls out industry leaders to accept responsibility for what they have created, to overcome their “tech hubris”, and to start investing some of their vast wealth into creating solutions:

”What if Bill Gates were to have an epiphany, realizing that the future health of his family—and indeed the global human family— depends on the deep greening of InfoTech? What if he were to commit himself to the thorough detoxification of the electronics industry by bringing his influence to bear on leaders in InfoTech and beyond?

What if he and other industry leaders were to publicly declare that InfoTech must prioritize the next generation of children the way it currently prioritizes the next generation of chips? What a lasting legacy that would be!”

The “Lightweb” needs to be guided by the principles of “benign by design” and Raffi cites leading sustainability thinkers and practitioners. He cites at length the “Vision for sustainable electronics” being developed by the Electronics TakeBack Coalition (of which I am the Chair), which envisions a future world where: materials and processes cause no harm; activities enrich communities; natural resources are protected; inputs and outputs of the manufacturing process are sustainable; working conditions are safe and healthy; and new business models prioritize sustainability and embrace lifecycle goals. In order to navigate this new path to sustainability, Raffi invites us all to participate in creating the new “Lightweb”.

Thank goodness for Raffi and hallelujah for “Lightweb Darkweb” – this new book is a beacon of light to lead us out of the current wilderness of the Dark Web and into a sustainable future. Citing Gandhi, he points us to a future where everyone has enough for their needs (but not their greed. Sometime it takes a troubadour to show us which way the wind is blowing.

Ted Smith has worked to promote sustainable electronics for over 30 years, as founder of Silicon Valley Toxics Coalition, Chair of the Electronics TakeBack Coalition, and Coordinator of the International Campaign for Responsible Technology. He is co-author and co-editor of “Challenging the chip” and lives in San Jose, California, which calls itself the “Capitol of Silicon Valley”.

Today we are releasing our first Report Card on the electronics retailers and their programs (or lack thereof) to help us recycle our old electronics. Staples, Best Buy, and Office Depot got the highest marks, as all three have robust programs that let consumers bring our items back to their stores for recycling.

But we gave F’s to nine of the 16 retailers we reviewed for having no real program. This includes retail giants like Walmart, Sams Club, Amazon, and Costco.

Another four, including Target and Radio Shack, got Ds for having limited programs.

Office Max was somewhere in the middle, mostly requiring people to mail products back, but notably taking printers and laptops back at their stores for recycling.

Retailers need to do their part

It’s time for these retailers to step up and start taking some responsibility for their role in the e-waste problem. They are selling us billions of dollars in electronics, but most are doing nothing to help us recycle them.

Walmart sold over $20 billion in electronics in the U.S. in 2012. They have 3742 stores, in all 50 states. Millions of people are buying their electronics there. Imagine if these were also recycling collection centers, that would be a big boost to the current e-waste collection infrastructure, especially in states with no e-waste recycling law.

Many of the retailers, including Walmart, tout their trade in programs, where you can mail back used items and get store credit. But the first problem is that they only take the small stuff that they can make money from (phones, tablets, cameras, etc.) and they don’t take the low value stuff that people really need help recycling – TVs, monitors, printers, VCRs, DVD players and other stuff you plug into your TV. And second, these are mail back programs. Most people won’t mail back anything but the very smallest stuff like phones. So it’s not surprising that these companies won’t disclose the volumes coming back from their mail-back trade in programs. It can’t be much. Retailers need to do what Best Buy, Staples, and Office Depot have done, and use their stores as e-waste collection centers. It should be just as easy for us to recycle our old stuff as it is to buy the new stuff.

The EPA released new figures recently that show that our recycling rates have increased, but we are still only recycling about 25% of the electronics that people are getting rid of. The rest is still going into the trash. The retailers are in an excellent position to help here, since that’s where we are buying most of these products.

We’d like to see the retailers partner with some of the manufacturers, particularly the TV companies, who always struggle to create collection opportunities for their recycling programs.

But we don’t just want to focus on the brick and mortar retailers. The online guys also need to step up. Amazon is the number #3 electronics retailer, selling $19 billion in electronics last year. True, it’s a more difficult proposition for them, since they don’t have stores. But Amazon has figured out how to set up a whole network of locker delivery locations, by partnering with various other retailers, including Staples, Rite Aid, Ace Hardware, and Seven Eleven. They could do the same kind of partnering to help their customers recycle their old electronics.

As consumers, we should give our business to the retailers who are doing the right thing, and helping us recycle. Why should we support the laggards, who are sitting on the sidelines and letting Best Buy, Staples, and Office Depot do all the work?

New figures just released by the EPA show that the U.S. generated 3.41 million tons of e-waste in 2011, up from 3.32 million tons in 2010. We recovered 850,000 tons, or almost 25% of that for recycling, up from 19.6% in 2010. But in the report, the EPA cautions that this apparent increase in the recycling rate is, “due primarily to better data, rather than a sudden growth in recycling.”

The figures come from “Municipal Solid Waste in the United States, 2011 Facts and Figures,” a report the EPA publishes annually waste from residential, commercial and institutional sources. The report shows that the e-waste recycling rate is considerably smaller than for some other product categories, summarized in the chart below, including auto batteries (96.2% recycling rate), major appliances (64.2%), and tires, (44.6%). Significantly, these are all product categories where the retailers play a major role in taking back the products, often when replacements are purchased.

The report does not represent all e-waste generation, but represents “selected consumer electronics” which include products such as TVs, VCRs, DVD players, video cameras, stereo systems, telephones, and computer equipment.

Comments from the Electronics TakeBack Coalition and the Basel Action Network

March 13, 2013. The International Trade Commission (ITC) has released a new report, “Used Electronic Products: An Examination of U.S. Exports.” It attempts to quantify the exports of used electronics from the U.S. to other countries, both developed countries (members of the OECD) and developing nations (non-OECD). While it fails to do this adequately for reasons discussed below, the report does contain important acknowledgments supporting the need for federal legislation, like the Responsible Electronics Recycling Act introduced in the 112th Congress. These are:

Report says RERA would increase exports of commodity grade materials and result in an increase of U.S. based recycling and refurbishment activity. Any increase in U.S. based recycling or refurbishment work would certainly increase U.S. jobs.“However, (if RERA were enacted into law) the product mix (of exports) would likely change to reflect more tested and refurbished products and fewer end-of-life products (exported). Conversely, exports of commodity-grade material would likely increase, as more recycling activity would take place in the United States and UEP-derived commodities would be exported to manufacturing centers in non-OECD countries.” Page 6-8“UEP” refers to used electronic products and “commodity-grade material” is the separated material from electronics (metals, plastics, glass, etc.) that recyclers sell to the manufacturing supply chain.

Report confirms that many recyclers don’t know what’s ultimately exported.The report appears to acknowledge the need for RERA by noting that as much as 41% of the respondents were “reasonably certain some portion of their UEP [used electronic products] output was later exported by another organization.” (Page xiii)
Both the fact that recyclers and other e-waste handlers are uncertain of the exact figure of exports and the exact destination of their exports confirms what proponents of RERA claim, that there is a strong likelihood that a significant portion of recycling in the US results in the export of unprocessed (and likely toxic) e-waste that is dumped abroad.

More than half the export volumes reported goes to end uses that are often problematic.The ITC figures on page 5-2 show that more than half of the 1.5 billion pounds of exported e-waste goes to the kinds of end uses that can be quite problematic in developing nations. This includes exports of untested or nonworking products, products for disposal, recycling and disassembly, and an incredible 18% of the volume going to unknown purposes.) See our analysis of this information at the end of this document.

Why survey methodology doesn’t, and can’t answer key questions

Unfortunately, the report doesn’t provide the kind of clear data that we need about e-waste exports. It completely fails to answer these key questions:

How much of our total e-waste gets exported to developing countries?

Does this report support or discredit the notion that much of the used electronics that get to recyclers actually gets exported to developing countries?

Here’s why:

1. Most data are presented as dollar value of used products sold, not numbers of units or weight of products.

Presenting data in terms of dollar values sold doesn’t really shed much light on issues of actual volumes sold, and what types of equipment is sold, or its toxicity and subsequent environmental harm. For example, circuit boards (whole and shredded) represent 38% of the exports by value, but only 17% of the volume (by weight, which is how most reporting on e-waste collection is done). The reporting on sales volumes simple does not help answer any of the key questions. While the report does give the weight of the equipment exported, it doesn’t report the weight of the total amount of e-waste generated.

2. The report’s data shows double and triple counting of the same equipment. (Page 2-3)

This survey asks companies to report on sales of used electronics. The respondents include U.S. companies from all parts of the supply chain – collectors, disassemblers, processors, reuse firms, brokers, asset recovery firms, etc. So the report is capturing sales by the collectors as well as sales by their downstream vendors, even though some of these sales were for the same volumes. The report’s construction makes it is impossible to tell which specific volumes referred to in the report, were reported multiple times. Clearly, some were.

For example, a collector sells a specific quantity of laptops, say a truckload, to a reuse firm. The reuse company then resells the same laptops to a broker. The broker then sells the same laptops (in a consolidated shipment along with other laptops) to a purchaser in another country. Clearly, the sales numbers in the report may represent that same truckload of laptops at least three times. This double counting results in a very serious skewing of results.

The report even acknowledges this double counting on page 2-3, using the seemingly innocuous term “cumulative sales:”

“…The sales value presented here is likely greater than the value of UEP material collected within the United States, since it reflects the cumulative sales for organizations throughout the UEP supply chain.”

3. Overstated domestic sales, understated export sales.

Because of the double (triple) counting problem stated above, the total figures on domestic sales (as opposed to exported sales) will be overstated. The report respondents acknowledge this, explaining that as many as 41% of the respondents saying that they were “reasonably certain some portion of their UEP output was later exported by another organization.” (Page xiii) But that’s not even mentioned in the “Key Findings” section, which shows that domestic sales represent 93% of sales (by dollar value) and exports only 7%. This could lead a casual reader to conclude that only 7% of used electronics are exported, which is not at all what the report actually says.

4. Survey format unlikely to get honest answers on illegal exports.

The ITC survey results underreport the volumes of e-waste exports to developing nations. This would be true of any report based on a survey of exporters. Why is this so? Exporting e-waste from the U.S. to non-OECD countries is illegal under international law. This practice is considered to be trafficking in hazardous waste, and has become such a big global problem that INTERPOL , the international policing agency, has launched a considerable effort to crack down on these exports. Thus, given that the practice is treated as a criminal enterprise, it is highly unlikely that a survey will ever yield accurate honest data about those exports. Clearly, there is a strong disincentive for an exporter to admit to exporting untested, or non-working e-waste to developing nations, when this is considered international trafficking in hazardous waste. Why would a company admit this illegal activity, especially to an agency of the federal government?

The report offers hints at some of the serious shortcomings of the survey methodology:

a) The ITC report admits that “The survey could not determine whether U.S. exports of UEPs bound for recycling or disposal in 2011 were sent to [informal processing] facilities”, those “with little regard to health, safety, and the environment.” (page xviii)

b) The ITC report admits that the limitations of the survey methodology could not “capture ad hoc shipments of undeclared UEPs mixed in with exports of other items.” (page xviii)

c) Respondents to the ITC survey offered the view that they “did not know the intended final use of nearly 18 percent…of US exports of UEPs.” (Page xviii)

NGOs such as the Basel Action Network have tipped off news outlets and enforcement agencies around the world about illegal exports from the U.S. In December of last year, EPA enforcement and Homeland Security achieved a criminal conviction of a Denver area exporter who will likely face jail time.

In light of the obvious deficiency of the survey method, one has to ask, “Why do a survey?” The ITC is a well-respected, capable research institute. However, the ITC was compelled to primarily use a survey for this research, since the request from the U.S. Trade Representative asking for research on e-waste exports specifically requested a survey. Thus, the deficiencies of the report were already baked in by the USTR’s mandate that the ITC use the flawed methodology of a survey.

5. Small companies not part of the survey.

The survey did not include small companies of 10 employees or less. But many of the “collect and export” type companies are quite small. Their whole business model is built around collecting products, loading containers, and exporting them to developing countries, which requires very little staff. Similarly, some brokers are also quite small. This survey didn’t include these either. We are not suggesting that small companies in general are more likely to be exporters, but these are two types of small companies which are quite numerous, and are known to be common exporters of untested, nonworking equipment to developing countries. Omitting them from the survey means underreporting of their problematic activities.

Our analysis of data on weight of used electronics exported

This is our analysis of the data discussed above under 3, “More than half the export volumes reported goes to end uses that are often problematic.”

The table on page 5-2 shows “End uses of exported UEPs (Used Electronic Products). Perhaps this is the most concrete information presented, although it assumes that the exporter actually knows the actual end use at final destination, which the report authors admit that they don’t really always know. As noted earlier, the report explicitly states that Respondents to the ITC survey offered the view that they “did not know the intended final use of nearly 18 percent…of US exports of UEPs.” (Page xviii)

The table does not separate end uses in OECD vs Non OECD countries. But it does show that exports of tested working equipment, and materials for smelting is less than half of what gets exported.

It shows that the total reported exports are 757,721 tons of used products, or just over 1.5 billion pounds. If we assume that the Materials Processing category is going to OECD smelters, which discussion later in the report suggests) and that the resale of working equipment isn’t overstated, then that still leaves more than half of the volume, or 7.73 million pounds, destined for potentially problematic export uses.

End Uses of Exported UEPs 2011

TONS

Pounds

Materials Processing (smelting, refining, sorting)

323,772

647,544,000

While “sorting” could mean anything, let’s assume this category goes to OECD smelting

Resale of whole equipment without further processing (tested/working)

47,071

94,142,000

Likely overreported in a survey, but let’s assume this is OK

Subtotal

370,843

741,686,000

Total we assume is OK

Recycling or disassembly

84,941

169,882,000

Resale of whole equipment or parts needing further processing

58,021

116,042,000

Non working or untested

Final disposal

5,768

11,536,000

Elsewhere in the report (p 3-9, table 3.3) it says exports for disposal total 241,279 tons, not 5768. No explanation is given for this mismatch.

White House agrees with consumers – we should be able to unlock our cell phones

In the U.S., when we buy a cell phone, it is usually “locked” to a particular cell phone carrier, like ATT or T-Mobile. You can’t use it on a different carrier without “unlocking” it, which involves entering a few codes on some phones, although it’s more complicated on other phones.

But recently, the cell phone carriers pressured the federal government to make it illegal to unlock a phone, even after the contract was up. The penalty can be an astonishing $500,000 and up to 5 years in jail, if you do this for commercial gain. While consumers probably might not face such a stiff penalty, think about all the phone refurbishers who sell used phones to second and third users. They need to be able to unlock phones in order to sell them to new owners.

This change prompted over 114,000 people to sign a petition to the White House, which led the White House to issue a statement yesterday saying it opposed this new change, and it thinks we should be able to unlock our phones AND tablets.

What changed?

Technically what happened was that effective January 26, 2013, the Library of Congress cancelled an exemption to the Digital Millennium Copyright Act (“DMCA”), which had allowed us to unlock our phones without the carrier’s permission. What in the world does the Library of Congress have to do with our cell phones? It’s because the software in your phone is copyrighted, and the U.S. Copyright office is part of the Library of Congress. The carriers say they believe that unlocking phones undermines the software encryption protection. Conveniently for them, if you can’t unlock your phone, you must continue to pay that carrier for service.

Why we need to be able to unlock our phones?

Freedom to switch carriers. With an unlocked phone, once your contract is up, you can switch carriers without buying a new phone.

Use your phone overseas: If you travel to Europe, you will incur expensive roaming charges if you use your GSM phone there. But with an unlocked phone, you can buy a different SIM card to use while you are there, saving a lot of money if you plan to use your phone.

Reuse. Probably the most compelling reason we should be able to unlock our phones is that an unlocked phone is much more likely to be reused, since it can be used on any carrier’s network. The environmental footprint from manufacturing new phones is significant, so anything that promotes the reuse of a phone to a second or third owner, is important and worth doing. This change has thrown a serious wrench into the business model of phone refurbishers who need to be able to unlock phones in order to sell them to new owners.

Ownership. Because we paid for our phones, so we should actually OWN them. If it’s locked, then we don’t really own it.

iFixit found that the Microsoft Surface Pro has so much glue holding the casing closed, they needed a heat gun to open it up. Photo by iFixit.

A new repairability scorecard from iFixit, the champions of easy gadget repairs, rates the repairability of the top tablet computers on the market, with a score from zero to ten.

Dell’s XPS 10 got the highest grade, a 9 out of 10. The lowest score (1 out of 10) went to the Microsoft Surface Pro, although the iPad mini, and iPads 2, 3, and 4 were right behind with only two points. The iPad 1 scored 6 out of 10, but the later versions are glued shut.

What makes a tablet more repairable?

Higher grades went to tablets where it is:

Easy to remove the casing (without breaking it) to gain access to the parts

Easy access to the things that will need replacement the most, like batteries, cameras

Easy to separate the LCD panel from the glass

Using certain fasteners instead of soldering parts in place. (Fasteners make it easier to remove the part without causing damage, and to reattach it later)

Modular design

Fewer screws overall and fewer sizes of screws in one product (requiring the repairer to change tools less frequently) The Microsoft Surface pro has 90 screws in it, compared to Dell XPS’s 20 screws.

What features get in the way of easy repair?

Gluing the case closed

Gluing the LCD panel to other parts – the glass and the bezel. If the screen gets cracked, you must replace all three parts.

Gluing the battery in place

Too many screws, hidden screws

Soldering parts in place, instead of using screws or other fasteners

Using proprietary screws, which require a special screwdriver

Gluing in parts is not “Design for the Environment”

Making these gadgets easy to repair (which equals cheaper to repair in most cases) means that the first owner is more likely to use it longer, plus it makes it more likely that it will get second lifetime. The lifecycle impact of manufacturing electronics products is huge, when you consider the materials (including critical minerals) used, energy, and water used to manufacture the products (including extracting and refining metals, and semiconductor and other component manufacturing). So designers should be doing everything possible to prolong the life of existing products by making them very easy (and cheap) to repair and refurbish.

Clearly Dell’s designers are paying attention to this aspect of Design for the Environment, as are Samsung and Motorola, according to this scorecard. We hope to see other companies do better with their future products.

IEEE decides to “take its ball and go home” from EPEAT rulemaking playground

Something really sinister has just happened related to the EPEAT effort to update the computer standards. It happened on the IEEE’s playground, during recess. Was it bad enough for the EPA and other stakeholders to take the EPEAT standard away from IEEE?

In case you are new to EPEAT, it’s a sort of “green” label for electronics. EPEAT stands for Electronic Product Environmental Assessment Tool. IEEE (pronounced “Eye Triple E”) is an enormous electronics industry professional organization, and it’s also the standards development organization (SDO) under whose rules and structure the EPEAT standards have been developed. (We’ve been using their playground.) Under this process, any stakeholder can participate in the meetings and votes to develop these standards, although the final balloting is done by dues paying IEEE members only. (Other stakeholders must pay to join IEEE to vote on the final ballot.) Once the standards are complete, the manufacturers’ products get evaluated against these EPEAT standards, and graded as EPEAT Bronze, Silver or Gold.

IEEE’s Playground Rules

IEEE invites the stakeholders to come to their playground to play and to bring their friends and their dollars. IEEE supplies the ball and jungle gym, and the swings, and you have to follow their playground rules (they even have a playground monitor with a whistle), but you can decide what you want to play. You can even modify some of the rules of your own game (called your Policies and Procedures), with IEEE’s approval. They’ve been inviting those of us interested in electronics over to their playground since 2005, when the EPEAT founders first approached them to be the SDO for the standard for computers (now known as IEEE 1680.1).

That has worked out better for some than others. The Big Kids, the major companies within the electronics and chemicals industry, pretty much always win because the playground rules are unbalanced and favor them. But EPEAT has still moved ahead modestly, recently releasing new standards for TVs and for “imaging equipment” which means printers, faxes, copiers, and multi-functions. The computer standard is six years old, however, and in serious need of revision, as most of the criteria are easily met by most computers, so they are no longer useful in identifying “leadership” products.

Rules of the eco-label game favor Big Electronics

In 2011, the playground “taskforce” that oversees all the kids working on electronics standards (it’s called the EASC Committee) developed new Policies and Procedures for developing future EPEAT standards, including the revision of the outdated computer standard. The new P & Ps included some changes to the rules on voting and how stakeholder group assignments are made. These changes would make the game a little more balanced so the Big Kids are not always guaranteed to win. They wanted to make sure voting is balanced (no stakeholder group can have more than 33% of the vote) even at the Working Group level (where all the work is done), not just at the final balloting. And initially, even the Big Kids on the taskforce supported these proposals.

IEEE doesn’t have to approve every set of P & Ps – only the ones they request to review. Initially, they didn’t request a review of these proposed P & Ps. But then last spring, they asked to review them. They came back to the EASC with requests to delete many of the proposed rule changes aimed at providing more balance.

When the EASC made some modifications and resubmitted their proposals to IEEE, it was again rejected, with even new concerns and arbitrary changes ordered. Efforts by the EASC over the summer and fall of 2012 to work through these issues with IEEE (all of which still adhere to the overall IEEE playground rules, mind you) were unsuccessful.

Playground bullies take over the “stakeholder” process

Then in December, IEEE suddenly stripped the EASC of its role in leading this stakeholder process. IEEE usurped this role and appointed its own three member “oversight group” that will make up their own P & Ps and decide how our little game is played. This new cabal will require elections of the working group chairs (which have always been appointed, not elected, until now – it’s a crucial role that should be an impartial person, not an elected stakeholder).

Basically, the playground bully decided to “take its ball and go home.” Or for South Park fans, Cartman told them, “Screw you guys, I’m going home.” It didn’t like how EPEAT was playing the game and trying to make the rules fairer. From now on, EPEAT can come onto the playground, but it must sit quietly on the bench, while the new cabal calls the shots. And the Big Kids, mostly hiding behind their industry associations, are just fine with this new arrangement.

It’s time to move to a new playground

Many of the groups in the Electronics TakeBack Coalition have been stakeholders in EPEAT for several years. We believe it’s time to find a new playground. IEEE has bullied this process long enough, without adding anything of real value, just obstacles to real progress. They may know how to oversee work on technical standards, but with sustainability standards they are a terrible fit. While in theory this is a “consensus stakeholder process,” the lack of balance and other IEEE rules have allowed the industry voters to whittle away at draft standards in exchange for changing their votes from no to yes. In the end, we are left with standards that are far too weak, far too limited, and that do little to move this industry forward on sustainability. But they have great potential which many of us would like to see realized. And that will never happen as long as we are under the IEEE stranglehold.

EPA, you were one of the original funders/supporters of this whole process. We hope you are ready for a change. Let’s start by immediately moving the computer standard revision away from IEEE and, for a change, onto a level playing field.

Both compact fluorescents and LED lightbulbs qualify as hazardous waste under California and EPA protocols

New research from scientists in California and South Korea, published yesterday in Environmental Science and Technology, shows that while compact fluorescent bulbs (CFLs) and LEDs have better energy efficiency than incandescent bulbs, they compare unfavorably when you look at their potential toxicity (at the end-of-life phase) and resource depletion.

First, let’s be clear that the study focused on the kinds of CFL and LED light bulbs you can screw into a lamp used for ambient lighting, not the LEDs used to light flat screen TVs or monitors (more on that later). Also, the study did not consider toxicity in the extraction or manufacturing phase – but just on the end-of-life phase, assuming they were trashed, not recycled (since sadly, most people do put used bulbs in the trash).

Because the bulbs have very different expected lifetimes, they “normalized” their data on resource depletion and toxicity potential by using data for fifty incandescents, five CFLs, and one LED bulb. Even after normalizing their calculations, the team found that CFLs have from three to 26 times higher resource depletion and toxicity potential than incandescents and LED bulbs have two to three times higher potential.

Metals

Both CFLs and LEDs have higher levels of metals than incandescents have, except for Tungsten (in the filaments) and nickel:

CFLs and LEDs require more metal-containing components that supply power to light the bulbs

CFLs and LED require one or more circuit boards (adding antimony, copper, lead, iron)

CFLs and LEDs use copper in the coils and zinc as protective coatings to stainless steel

CFLs contain mercury, phosphorous, and yttrium

LED bulbs include a heat sink to dissipate the heat (adding aluminum)

LED chips include antimony and gallium

LEDs use barium and chromium in stainless steel, and phosphorous, silver and gold elsewhere

With so many metals used, including some critical metals, we need to see more recycling and less trashing of all these bulbs.

CFLs and LED bulbs flunk hazardous waste test

All three bulbs were tested to see if they should be classified as hazardous waste, under the protocols established by Federal EPA (the TCLP test) and California Department of Toxic Substances Control (the TTLC methodology). The CFLs and LED bulbs were both determined to be hazardous waste, but the incandescent bulbs were not. Both the CFLs and LED bulbs far exceeded the federal TCLP levels for lead and the California TTLC level for copper. The CFLs also far exceeded the California levels for zinc. While the CFLs measured just below the California level for mercury, the authors state that the methods used for sampling did not capture the mercury that could have vaporized when the CFL bulb was broken. (This may mean that the primary concern could be the exposure to whomever breaks, or cleans up a broken CFL bulb, even more than what happens in the trash.)

Toxicity

The study evaluated the hazard based toxicity potential (on a per bulb basis), using two different methodologies. Both showed the CFLs and LEDs have higher hazard potential than incandescents because of copper, aluminum and zinc. CFLs and LEDs also had higher scores for human and eco-toxicity potentials. “The CFLs exhibit at least 2.5 and 1.3 times higher human- and eco-toxicity potentials than the LEDs, respectively, and the CFLs and LEDs exhibit at least 2 orders of magnitude higher potentials than the incandescent bulb,” according to the report.

What about LEDs in flat panel TVs and monitors?

The next logical question is what this kind of evaluation would find if focused on the LED components that light TVs and monitors. The University of California researchers have evaluated individual pin type LEDs, like those used as indicator lights in electronics. But given that some of the impacts from the LED bulbs studied here come from the ancillary components needed not just to light one LED, but to light the bulb, we would be very curious to see studies that look at the full array LED backlights or edge lights in TVs to determine, in particular, whether they should be classified as hazardous waste or not.

Executive Recycling’s fake recycling was featured in a 60 Minutes episode in 2008.

A federal court in Colorado today convicted the executives of Executive Recycling, formerly of Englewood, Colorado, of multiple counts of mail and wire fraud, obstruction and environmental crimes related to illegally disposing electronic waste and smuggling.

This company was featured in the 2008 CBS News’ 60 Minutes Episode, “Electronic Wasteland,” on how e-waste from the U.S. is collected by companies claiming to be recyclers, who instead load it up on containers and ship it to developing nations. Like many fake recycelrs, Executive Recycling promoted itself as an environmentally responsible company.

The charges came after the Basel Action Network (BAN), a toxic trade watchdog organization, which is a member of our Coalition, observed and photographed 20 seagoing containers leaving the Executive Recycling loading docks and tracked them overseas. BAN then gave the information to Environmental Protection Agency (EPA) Enforcement, the Government Accountability Office, and CBS News.

The 60 Minutes team followed one of Executive’s containers to China with BAN’s Executive Director Jim Puckett. Following that episode, investigations by EPA Enforcement, Homeland Security, Immigration and Customs Enforcement (ICE), and the U.S. Attorney led to an indictment of Executive Recycling on 16 criminal counts, and eventually to today’s conviction

We applaud the federal government for mounting this investigation and pursuing this lawsuit. This practice of fake recycling is all too common in the U.S., and most of them get away with it. While exporting e-waste to China and other developing countries is common, it’s unusual for most fake recyclers to be brought to court, because much of their activity is perfectly legal under U.S. law. Because Executive Recycling was exporting Cathode Ray Tube (CRT) TVs and monitors, they violated the one regulation on the books (the CRT rule) pertaining to e-waste exports from the U.S. According to Homeland Security, Executive Recycling exported over 100,000 CRTs from the United States between 2005 and 2008. Because of the company’s particular behavior, prosecutors were able to add charges of obstruction of justice, and wire and mail fraud, in addition to environmental violations.

But it wouldn’t take such a monumental effort by the EPA, Homeland Security, ICE, and the U.S. Attorney to stop fake recyclers like this if we passed legislation, like what most of the rest of the world has, that would make this kind of global e-waste dumping illegal. Such legislation was introduced in this past Congress as the Responsible Electronics Recycling Act, and is expected to be reintroduced in the new Congressional session next year.

CRT glass “crisis” shows why we need to design the toxics out of electronic products

Today is America Recycles Day, but this year we might need to change it to “America Stockpiles Toxic CRT Glass Day.” A new study shows that many electronics recyclers across the U.S. have collected payments for recycling our old CRT (cathode ray tube) TVs and monitors, but then instead of actually sending the toxic leaded CRT glass to proper glass processors, they simply stored this glass on their property or other locations.

Cathode ray tubes from old TVs or monitors can contain 4-8 pounds of lead.Photo: Dreamstime.

EPA regulations limit what they call “speculative accumulation” of used CRTs or CRT glass, both because of their potential to release toxics into the environment, and because of concerns that companies might abandon sites with piles of toxic glass, leaving them to become federal Superfund toxic clean-up sites.

Recyclers have stockpiled an astonishing 860 MILLION POUNDS of CRT glass in the U.S., according to a new report from Transparent Planet, entitled “U.S. CRT Glass Management: A Bellwether for Sustainability of Electronics Recycling in the United States.” The bulk of that glass is said to be in the Southwestern states (500 million pounds) and California (200 million pounds). The report findings were presented today by the author, Lauren Roman, Managing Director of Transparent Planet to an e-waste conference.

Get the Lead Out

We all know that “normal” glass is pretty easy to recycle, and in many places they pick it up from our curbside bins for recycling. But CRT glass isn’t easy to recycle because it contains a lot of lead, which is very toxic. Typical CRT TVs or monitors each contain 4-8 pounds of lead in the glass tube, and the inside of the tubes get coated with toxic phosphor dust. While virtually no one in the U.S. is buying new CRTs anymore (we’ve moved on to flat panels), CRTs still comprise a significant amount (often over 60%) of what is coming back in electronics recycling programs, especially from consumers who have been retiring their tube TVs in a steady flow since the Digital Conversion in 2009. Because lead is very toxic, it’s important that CRT glass is managed safely and responsibly. Many states have passed bans on putting CRTs in their landfills or incinerators. Federal law also bans them but the law contains a big (and in our opinion, ridiculous) exemption for people who generate small quantities of waste (like consumers and small business).

Recyclers have typically had two options for what to do with CRT glass: send it for glass-to-glass recycling, where it is used as a feedstock to make new CRTs, or send it to a lead smelter where the lead is separated out for other applications (but the smelting usually results in toxic air emissions). The glass-to-glass recycling business has mostly disappeared, as there are not many CRTs being manufactured any more in the world. And the few lead smelters in North America have limited capacity, and they are expensive.

Manufacturers Don’t Pay Enough for Proper CRT Handling

With shrinking options for processing CRT glass, the economics of recycling CRTs have turned upside down in just a few years. According to the report, where recyclers used to earn $205 per ton recycling CRT glass in 2004, they must now pay $200 per ton, a net loss in value of $405/ton in eight years. The problem is that most of the electronics manufacturer takeback programs are not paying their recyclers enough per pound to manage this toxic glass properly.

Other Key Findings From the Report:

California stockpiles. Even in California, where the state program reimburses recyclers 39 cents per pound, some recyclers are still stockpiling glass. The State of California is so worried about the stockpiles that they have issued emergency regulations and will now (for the next two years) allow leaded CRT glass collected under their electronics recycling program to be disposed of in the State’s hazardous waste landfill.

Billing for more than what’s been collected. The CRT Report also documented a problem that’s been whispered about for a while in this industry – referred to as “air pounds” or “ghost weight.”

Ghost weight – That’s where a recycler charges a manufacturer’s takeback program for more e-waste than they’ve actually collected. Since weight records are not usually required for material collected at public collection events, some recyclers quote very low prices per pound to the manufacturers to get the work but then claim they collected twice the material than they actually did so they can bill the manufacturers for more than they actually collected.

Air pounds – Paper transactions are created between recyclers that often do not represent actual material recycling but rather a ‘recycling’ of paperwork that is used to “prove” recycling occurred…used over and over again.

Some recyclers tell me that they believe that some manufacturers are aware of this problem, but have little incentive to bust recyclers for these deceptive practices as long as they are able to claim the higher volumes towards their (manufacturer) collection goals, and still pay a very low price per pound. But it also takes away business from the responsible recyclers who don’t use ghost pounds, and who won’t sign a contract for CRTs if the price is too low to process it safely.

Changes to State Laws Could Resolve Both Problems

Both of these problems, CRT stockpiling and ghost pounds, is happening both in states with e-waste laws and in states without e-waste laws. Twenty four states have passed e-waste recycling laws, with 23 of them (all but California) based on Extended Producer Responsibility (EPR), which makes the manufacturers financially responsible for recycling their old products. The States didn’t anticipate these problems; neither did we, as advocates for EPR laws. But clearly there is a need for a little more State oversight into the details, including:

Establishing base line pricing for responsible CRT glass management

Requiring third-party mass balance monitoring of collection volumes, so that the only “proof” of pounds comes from the third party entity

Bottom line – Product Redesign is the Answer

None of these problems would exist if electronics were designed in a way that the materials were valuable enough and easy enough to recover for new manufacturing. CRTs are the poster child for not designing with the product’s end-of-life in mind. Maybe that’s not a fair criticism, since CRTs were designed back before anyone was thinking about recycling electronics. But the industry still isn’t designing with recycling in mind. They moved from leaded glass CRTs to flat panels using fluorescent lights with highly toxic mercury in them. And used panel “glass” from LCD TVs and monitors do not currently have much recycling value so some recyclers are just landfilling them.

It’s time for this industry to challenge their designers and chemists to design products using safe materials that make their products just as valuable at the end of life as they were when the companies sold them.